ML19296B908
| ML19296B908 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 02/14/1980 |
| From: | Goodwin C PORTLAND GENERAL ELECTRIC CO. |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| TAC-46275, NUDOCS 8002220355 | |
| Download: ML19296B908 (24) | |
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February 14, 1980 Trojan Nuclear Plant Docket 50-344 License NPF-1 Radiological Emergency Plan Director of Nuclear Reactor Regulation ATTN:
Mr. A. Schwencer, Chief Operating Reactors Branch #1 Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Sir:
On December 4, 1979, Portland General Electric Company (PGE) submitted a draf t copy of the Trojan Radiological Emergency Plan for your review.
On January 14 and January 18, 1980, we conferred with Mr. T. McKenna of the Emergency Planning Review Team concerning his comments on Chapter 1 of the Plan (the PGE Radiological Emergency Response Plan for the Trojan Plant [RERP]). We have also been in contact with Mr. A. Desrosiers and Mr. R. Fish of the Review Team concerning their comments on the RERP.
As a result, we are hereby submitting to you as attachment,s "to this letter our responses to the Review Team comments. We believe that all of the outstanding issues have been resolved, with the following exceptions:
- 1) We disagree with the requirement that offsite emergency agencies be notified within 15 min. of the occurrence
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Portland General Electric Ccupeny Mr. A. Schwencer February 14, 1980 Page 2 of an Unusual Event. Fifteen minutes notification time is the same required for other emergency categories, including a General Emergency. Given the fact that an Unusual Event by definition results in no offsite danger to the public health and safety, we believe that the notification time for this emergency should be decided by mutual agreement with the State and county emergency agencies involved.
- 2) We disagree with the requirement in NUREG-0610 for a written closeout summary to all offsite Emergency Oper-ations Centers within 24 hr. for an Unusual Event and within 8 hr. for the remaining emergency classifica-tions. The Trojan plant Technical Specifications con-tain extensive reporting requirements that include those occurrences which would be classified as an Unusual Event, Emergency Alert, Site Emergency or General Emergency. The State of Oregon Department of Energy receives a copy of all correspondence from PGE to the NRC. We believe that the need for further written followups to other State and county emergency agencies should be decided by mutual agreement between PGE and these agencies.
- 3) Two issues identified by Mr. T. McKenna as being con-tained in the new NRC-FEMA Criteria for Preparation and Evaluation of Radiological Emergency Response Pre-paredness will be addressed following public comment and finalization of the new criteria:
a) Staffing requirements for off-hours shifts.
b) New criteria for meteorological instrumentation.
We will submit a revised RERP containing the changes discussed in the attachment by April 1, 1980.
In addition, the implementing procedures for the RERP will be submitted for review by June 1,1980. The emergency response plans of Cowlitz County, Columbia County, and the States of Oregon and Washington are currently being revised to reflect the new
Portland General ElectricCcmpany Mr. A. Schwencer February 14, 1980 Page 3 NRC-FEMA acceptance criteria. At this time, we anticipate that a com-pleted Trojan Radiological Emergency Plan which includes the State and county plans, will be submitted for review by June 1,1980.
We look forward to discussing our responses with you as soon as possible.
Sincerely.
-Q
'/
YF C. Goodwin, Jr.
Assistant Vice President Thermal Plant Operation and Maintenance CC/TDW/SGG/4sa5A21 Attachments c:
Mr. Lynn Frank, Director w/ attach State of Oregon Department of Energy Mr. Ed Chow, Director w/ attach State of Washington Department of Emergency Services Mr. John DeFrance, Director w/ attach Columbia County Department of Fmergency Services Mr. Nolan Lewis, Director w/ attach Cowlitz County Emergency Services Mr. Richard Donovan w/ attach Federal Emergency Management Agency e
ATTACHMENT 1 COMMENTS BY T. McKENNA COMMENT 1 Item 5 on Page 3.2.1 states, "These agreements are reviewed and updated at least every 2 years (Section 6)", however, the dates on the agreements found in Appendix A of the RERP do not reflect such a review and update.
In order to comply with the regulatory position set forth in Regulatory Guide 1.101, Section 8.2, the review of the written agreements must be documented in the plan to include the date of last review and reviewing authority.
RESPONSE
All applicable agreements were updated in 1979 with the exception of the Columbia County agreement; this agreement will be updated by June 1, 1980. Documentation will be added to Appendix A to reflect this and future updates, including dates of reviews and reviewing authority.
COMMENT 2 In order to comply with the regulatory position set forth in NUREG-0610, the facility must always recoumend protective actions in the event of a
" general" emergency. Revise the following quote from Section 4.1.4 of the RERP to clearly reflect this position: " Initiation of predetermined protective actions for the public will likely be required, including sheltering and/or evacuation."
RESPONSE
This sentence will be revised to read: " Initiation of predetermined protective actions for the public will be required, including sheltering and/or evacuation."
COMMENT 3 The Emergency Action Level.s (EALs) listed in Tables 4.1-1,
-2, -3 and -4 and Table 4.2-1 are undergoing separate staff review.
In order to comply with the regulatory position set forth in Regulatory Guide 1.101, Section 4, the RERP must be revised to include EALs which relate to the Health Education and Uelf are/ Food and Drug Administration (HEW /FDA) ingestion pathway response levels.
RESPONSE
A new Table 4.1-5 will be added listing EALs for ingestion pathways.
COMMENT 4 In order to comply with the regulatory position set forth in Regulatory Guide 1.101, Section 5.2.1, the RERP must specify the line of succession of the authority of the Emergency Coordinator if the Shif t Supervisor is unavailable during nonnormal hours and the criteria for going to the next in authority.
RES PONSE Section 5.2.1 will be revised to spec'.'y the order of succession during off-hours as:
Shif t Supervisor Control Operator Assistant Control Operator In addition, Section 5.2.1 will be revised to state that the Emergency Coordinator will not delegate his authority during an emergency situation unless he is physically or otherwise unable to perform his duties.
COMMENT 5 In order to comply with the regulatory position set forth in Regulatory Guide 1.101, Section 5.2.2, the RERP must identify who, among the off-hours sraff, performs the following vital duties, tasks or functions during the initial phases of an emergency (before the staff can be augmented):
a.
Calculation of projected offsite doses and determination of recommanded projected actions.
b.
Radiological monitoring and decontamination of onsite personnel and the public being evacuated.
c.
Radiation surveys / assessments.
d.
Offsite communications.
e.
Plant operations.
f.
sampling and analysis as required by NUREG-0576, 2.1.8.a.
RES PONSE A table will be added to Section 5.2 of the RERP to show the manning requirements on off-hours shifts for the above duties. The table will specify how the 1anning will be augmented by the day-shif t personnel and will include aur r atation times.
COMMENT 6 In order to comply with the regulatory position set forth in Regulatory Guide 1.101, Section 5.2.2 and Figure 5.2.2 of the RERP must be revised to identify the function, relationships and manning of the following:
a.
Fire fighting.
b.
First aid.
RES PONSE Section 5.2.2 and Figure 5.2.2 of the RERP will be revised,to state that the following personnel will perform the above duties:
Fire Fighting:
Fire Brigade, composed of a leader, two Auxil-iary Operators and two Security Guards. Upon implementation of this plan, the leader will be a designated member of the Plant Staff other than the Shif t Supervisor.
First Aid: Radiation Protection Team. This responsibility is defined on Page 5.2-14 of the RERP. Addi-tional clarification will be added.
COMMENT 7 In order to comply with the regulatory position set forth in Review Guideline 1, Acceptance Criterion I.A.2, the RERP must specify that the minimum emergency organization will be augmented within 60 min.
The plan must specify.the personnel and their function who will be available ta augment the off-hours shifts within 60 min.
RES PONSE The revision of the Draft RERP which was sent to the NRC as replacement pages on December 19, 1979 contains this basic commitment. The manning table described in the response to Comment 5 above will detail the personnel who will be available to augment the of f-hours shif ts within 60 min.
COMMENT 8 Comment withdrawn.
COMMENT 9 The county plans and Section 6.4.2 of the RERP indicate that county sheriffs will implement protective actions while Section 5.4.2 indicates this will be accomplished by the county EOCs. Revise the plan to resolve this apparent conflict.,
RESPONSE
Section 5.4.2 will be revised to clea.ly state that the county sheriffs Laplement protective actions. Communications and protective action decisions come from the county EOCs.
COMMENT 10 In order to comply with the regulatory position set forth in NUREG-0610, offsite officials must be informed of an Unusual Event, Emergency Alert, Site or General Emergencies within 15 min of its detection.
Tables 6.0-1,
-2,
-3, and -4 and Sections 6.2.1.1, 6.2.1.2 and 6.2.1.3 of the RERP must be revised to reflect this position.
RESPONSE
We will modify the above Tables and Sections of the RERP to state that the sf fsite officials responsible for implementing public: notification and protective actions will be informed within 15 min. of an Emergency Alert, Site Emergency or General Emergency. However, we seriously question the need for 15 min. notification of an Unusual Event. Given the fact that an Unusual Event by definition results in no danger to the public health and safety, we believe that the notification time for this emergency should be decided by mutual agreement with the State and county emergency agencies involved.
COMMENT 11 In order to comply with the regulatory position set forth in NUREG-0610, offsite authorities must be provided with Plant status updates at least every 15 min., if conditions warrant, during an emergency alert.
Table 6.0-2 must be revised to reflect this position.
RESPONSE
We will modify Table 6.0-2 to reflect this position.
COMMENT 12 In order to comply with the regulatory position set forth in Regulatory Guide 1.101 Section 6.1, Review Guideline 1, Acceptance Criterion IV.B.2 and NUREG-0610, the RERP must identify the type of information to be provided to offsite authorities. This must be coordinated with the State and local authorities to ensure compatibility.
RESPONSE
New Tables 6.1-2 and 6.1-3 will be added to give the informatioa required for initial notification and for continuing updates for the Emergency Alert, Site Emergency and General Emergency classifications.
COMMENT 13 In order to comply with the regulatory position set forth in Review Guideline 1, Acceptance Criterion II. A.5 and II.B.5, provisions must be made to alert and give clear instruction to the population-at-risk within the plume EPZ within 30 min. of detection (reaching EALs) of a " general" emergency at the site. Sections 6.2.1.4 and 6.4.2 of the RERP states that notification of offsite population-at-risk will be initiated within 30 min.
This must be revised to provide for essentially complete noti-fication of the population-at-risk within 30 min.
RESPONSE
We will change the above sections to require completion of notification of the plume EPZ within 30 min. of accident detection for a General Emergency.
COMMENT 14 In order to comply with the regulatory position set forth in Review Guideline 1, Acceptance Criterion II.A.4, provisions must be made to quantify the releases when the current instrumentation is offscale (before NUREG-0578, 2.1.6 requirements are met). This quantification of release must be accomplished in a timely manner allowing notification of of fsite authorities within 15 min. of the detection of the event of the protective actions to be taken. Section 6.2.2.1.1 of the RERP indicates that " grab samples" will be taken if the PRMs are offscale.
The plan must commit that these samples can be taken, analyzed and the results used to determine the protective actions to be recommended offsite within 15 min. of the detection of the event. This.must be done for the manpower available during the off-hours shift.
RESPONSE
The PGE response to NUREG-0578 Issue 2.1.8.a (Interim Sampling Proce-dures) states that samples can be takea and analyzed for gross activity (noble gas or iodine) within 15 min.
Section f.2.2.1.1 of the RERP will be modified to state that samples will be obtained and analyzed for gross activity within 15 min. of a PRM going offscale or malfunctioning.
COMMENT 15 In order to comply with the regulatory position set forth in Regulatory Guide 1.101, Section 6.4.1, provisions must be idertified in the RERP for monitoring of the Plant personnel and the public being evacuated from the site. The RERP must identify who will perform this function (including weekends).
In addition, provisions must be made to direct evacuees to a point beyond the plume.EPZ for further monitoring, etc. if required.
RESPONSE
- 1) The general public will not be monitored onsite; any monitoring of specific individuals that may be required will take place at recep-tion centers. Evacuees will be directed to reception centers by guards evacuating the site. Plant personnel will and members of the public on Plant tours will be monitored at the ECC.
- 2) Radiation Protection Technicians will perform monitoring of Plant evacuees at the ECC.
The VIC staff is responsible for setting up the ECC monitoring stations to ensure the monitoring equipment is available when required. All Plant employees are trained to moni-tor themselves for contamination. Therefore, on weekends, self-monitoring will be done until Radiation Protection Technicians arrive. During night shif ts, Plant evacuees will wait at the southeast entrance to the VIC for Radiation Protection Technicians to arrive (the number of evacuees during night shif ts will normally be small).
Section 6.4.1 will be modified to reflect these changes. The Cowlitz and Columbia County emergency plans will describe the operation of the reception centers.
COMMENT 16 The notification of the Columbia County Sheriff to set up check points on U. S. Hwy 30 must include consideration of projected offsite doses and current accident conditions.
RES PONSE PGE will work with Columbia County to include consideration of projected offsite doses and current accident conditions in the notification to' set up check points on U. S. Highway 30.
COMMENT 17 In order to comply with the regulatory provisions of Regulatory Guide 1.101, Section 6.4.1, provisions must be made for timely reloca-tion of persons to prevent or minimize exposure. The provisions made for river evacuees under which they remain at the evacuation ramps until they have been surveyed may not be adequate under all accident condi-tions.
The RERP must specify the time required for monitoring teams to arrive at the evacuation ramps (all sh'.f ts) and what provisions have been mtde to alert these people to procead to an alternate location beyond the plume EFZ before they are monitored if conditions warrant.
e
RESPONSE
Section 6.4 of the RERP will be revised to state that river evacuees will not be required to remain at boat ramps.
Information leaflets dropped to the boaters will provide directions to the reception centers. Trans-portation will be provided to move the evacuees from the designated boat ramps to the reception centers. A new Figure 6.4-2 and revised Section 6.4 will reflect thece changes.
C0KKENT 18 In order to comply with the regulatory position set forth in NUREG-0610, protective actions must be established for the total range of conditions that may exist during a " general" emergency. Therefore, the RERP must be revised, including Table 6.2-6, to identify the protective actions associated with " general" emergencies for which dose projections cannot be made (eg, loss of physical control of the facility).
In addition, the Plant and accident conditions which will initiate the reconmending a particular set of actions offsite must be described along with this relationship to the recommendations.
Section 6.2.2.1 must also be revised to indicate that protective action may be taken based on Plant conditions.
RESPONSE
Section 6.2.2.1 and Table 6.2-6 will be modified to define protective actions for General Emergencies for which dose projections cannot be made.
COMMENT 19 In order to comply with the regulatory position set forth in Review Guideline 1, Acceptance Criterion II.A.5, the RERP must provide for recommending protective actions for the ingestion pathway. These recommendations do not have to be made within 15 min. (see Comment 3).
RESPONSE
Section 6.4.4 will be modified to require calculation of ingestion pathway doses and to provide for recommending protection actions in a timely manner (1-2 hr.).
These calculations add recommendations will be mede by the Oregon State Health Division and the Washington Depart-ment of Social and Health Servi' es at the combined dose assessment centar c
at the ECC.
COMMENT 20 In order to comply with the regula< cry position set forth in Review Guideline 1, the provisions for river evacuation must be extended to include the total plume EPZ.
6,
RESPONSE
Figure 6.4-2 will be modified to include evacuation of the total plume EPZ up and down river. Reception centers and additional boat ramps (if needed) will be identified in Figure 6.4-2.
COMMENT 21 In order to comply with the regulatory position set forth in Regulatory Guide 1.101, Section 6.5.2, the RERP must identify by position title those individuals trained to perform first aid during each shift.
RESPONSE
Chemistry and Radiation Protection (C&RP) Technicians are trained in first aid, as stated on Page 5.2-14 of the RERP. At least one C&RP Technician is onsite during each shift. A more detailed description of the first-aid training will be provided in Section 5.2.
COMMENT 22 Describe the provision to ensure that the ECC responsbilities can be transferred in a timely manner to the alternate ECC if required.
RESPONSE
Section 6.1, Table 6.1.1, Figures 6.1-1 through 6.1-4 will be modified to state that the alternate ECC will be prepared for activation at the same time that the ECC is activated. Emergency supplies required to activate the alternate ECC will be stored at the St. Helens office. An inventory of these supplies will be listed in Appendix D.
COMMENT 23 Comment withdrawn.
COMMENT 24 In order to comply with the regulatory position set forth in Review Guideline 1, Acceptance Criterion III.A.2, licensee monitoring must not be limited to the LPZ. The RERP must be revised to provide for moni-toring beyond the LPZ if requested by local authorities.
RESPONSE
Section 7.3.2.1 of the RERP will be revised to allow PGE monitoring teams to monitor beyond the L?Z if requested by State officials. Maps will be provided in Appendix C-2 for this purpose.
COMMENT 25 In order to comply with the regulatory position set forth in Section 8 of Regulatory Guide 1.101, the RERP must commit all personnel holding any of the positions responsible for a vital emergency task identified in the RERP will be trained and qualified, possibly during a drill, to perform these tasks once every 12 months.
In cases where the task if not assigned to a specific job assignment title, all personnel who fall within the group described as performing the task or function in the plan must be trained and qualified.
RESPONSE
Section 8.1.1 of the RERP will be revised to reflect the above comment, including designation of specific individuals who will be trained.
COMMENT 26 In order to mee't the regulatory position set forth in Section 8 of Regulatory Guide 1.101, the RERP must specify that training will be offered every 12 months to:
a.
Local response agencies:
- 1) Fire;
- 2) Police;
- 3) Ambulance / rescue.
b.
Agencies responsible for implementation of protective measures.
c.
Coast Guard.
d.
Local press.
e.
Any other group having a vital role during an emergency (list in plan if any).
The plan must briefly describe the training to be offered. This must include topics which are unique to their role at the Trojan site, such as:
a.
Notification procedures.
b.
Basic radiation protection (if not provided elsewhere),
c.
Site access and security procedures.
d.
Role and authority / responsibility.
e,
The press must be of fered training on possible accident conditions and their relationship to the protective measures to be recommended and on the implementation of protective measures.
Local response agency officials must be offered training on EALs, their relation to Plant condition, protective actions and their implementation.
RESPONSE
Section 8.1.1 of the RERP will be modified to reflect the above position.
COMMENT 27 Comment withdrawn.
COMMENT 28 Comment withdrawn.
COMMENT 29 It is the Staff's position that the RERP must contain a commitment to provide extra equipment to permit replacement of items removed for testing or maintenance. The plan must commit that the procedures will specify the minimum amount of operable equipment to be maintained. In addition, the RERP must specify how often equipment will be tested and inventoried.
RESPONSE
- 1) All emergency equipment is inventoried and/or calibrated quarterly.
- 2) Emergency supplies listed in Table 7.3-10, Section 7.4.2, and Table 7.5-1 are required to be maintained.
- 3) Items removed for testing or maintenance are required to be replaced.
Section 8.3 of the RERP will be revised to include and/or clarify the above statements.
SGG/4sa66.51A1,
ATTACHMENT 2 COMMENTS BY R. F. FISH (Only Comments Requiring a Response are Detailed Below)
COMMENT 1 The plan appears to be inspectable. The licensee's portion of the plan identified certain procedures that will be incorporated in Appendix C.
Those procedures in C-2 have been identified by title; however, those in C-1 have not been specifically identif' -
We should request the titles of procedures to be placed in C-1.
RESPONSE
Procedures in Appendix C-2 will be forwarded for review by April 1,1980.
Appendix C-1 will contain only the titles of Plant procedures that relate to the RERP and are contained in other Plant documents. The listing of these titles will be forwarded by April 1,1980. The procedures them-selves will be submitted for review by June 1,1980.
COMMENT 2a The licensee sent an October 17, 1979 letter to Darrell Eisenhut in which they discussed their responses to NUREG-0578 and the scheduled implemen-tation. This document indicates present noble gas instrumentation (max 300 uCi/cc) is felt to be adequate. The revised emergency plan appears to use current instrumentation in determining releases.
It appears we must assume changes in instrumentation required by NRR in connection with NUREG-0578 will result in subsequent related changes to the revised emergency plan.
RESPONSE
The RERP will be revised to include the instrumentation required by NUREG-0578 upon installation of the instrumentation.
COMMENT Eb The licensee has indicated they will decide on an acceptable arrangement for notifying the population-at-risk within 30 min. by April 1,1980.
The dcscription of this system (s) should also include a date of Lnplemen-tation. The county plans describe the present system which involves deputy sheriffs going door-to-door.
Presently it cannot be determined whether the licensee responded satisfactorily to Item 3 [of the Review Team questions).
RESPONSE
The early warning system for the population at risk within the plume EPZ will be installed by January 1,1981, if equipment delivery permits. The County plans are currently undergoing revision to reflect the new warning system.
COMMENT 3a NUREG-0601 indicates that the licensee should subtit a close out written summary to offsite authorities within 24 hr for a " notification of Unusual Event" and within 8 hr for the other three classificatins. The licensee's revised plan does not require a written summary to offsite authorities for any of the four classifications.
RESPONSE
See response to Comment 9b below.
COMMENT 3b Also, NUREC-0610 indicates the following plan:
Classification NUREG Item NUREG-0610 Trojan Site Emergency 6
15 minutes 30 minutes 7
15 minutes 30 minutes 11 15 minutes Not shown Additional differences between NUREG-0610 and the 'icensee's Classifi-cation System (Tables 4.1-1 through 4) were identified as:
Classification NUREG Item Difference Notification of 8, 9, 11, 13 Not covered in Trojan Unusual Event Plan
RESPONSE
Responses to comments on emergency action levels (Tables 4.1-1 through 4.1-4) will be submitted following completion of the detailed NRC review of the EALs described in the response to McKenna Comment 3.
COMMENT '4 The licensee has adopted the NUREC-0610 classification system but the States and Counties have not yet made a similar change. With respect to the licensee's EAL's, I would comment as follows:
COMMENT 4a Item 6, Table 4.1-2 shows an unexpected ARM reading of 1 R/hr for L LM-11.
This instrument reads the radiation levels in the control room and I wouldn't expect it to reach 1 R/hr. The high alarm setpoint for ARM-11 (according to Table 7.3-6) is 10 mR/hr. Thus, the 1 R/hr appears to be too high.,
RESPONSE
The value for ARM-ll in Table 4.1-2 will be changed to 10 mR/hr.
C0KKENT 4b Item 10, Table 4.1-3, includes an analysis of a sample as part of the FAL. Meeting this set of criteria would be too time consuming because of the analysis needed in order to act in a timely manner.
RES PONSE See response to McKenna Comment 14.
COMMENT 4c Item 1, Table 4.1-4 requires a " dose assessment" calculation before concluding that the EAL was met.
This table concerns a general emergency and it is not likely there would be time to make such a calculation.
Meter readings only should be used. Also the EAL references "PRM levels" specified to Table 4.1-3 to find these F2M levels. Therefore, they should be listed in this table (4.1-4) also.
RESPONSE
- 1) See response to McKenna Comment 14.
- 2) The EALs in practice will be dispersed throughout individual Plant emergency proceduras and will not be used as four complete and sequential tables. The EAL referred to (Item 1, Table 4.1-4) will have individual PRM readings listed when it is reproduced in the Plant Emergency Instructions.
COMMENT 5 Because the procedures to be included in Appendix C-1 have not been specifically identified, licensee response to this item cannot be determined. The Counties and both State plans show the information expected from the Trojan plunt.
RESPONSE
See responses to Comment 1 above and,McKenna Comment 12.
COMMENT 6 Page 5.1-16 Under ECC Staff is the Radiation Protection ECC Team.
Is this the same team that is called the " Decontamination Team" in Figure 5.2-2:,
RESPONSE
The " Decontamination Team" referred to in Figure 5.2-2 should be called the Radiation Protection Team. This change was included in the replace-ment pages forwarded on December 19, 1979.
COMMENT 7 Page 5.2-18 says the Security Supervisor reports to the Engine 3 ring Coordinator. Figure 5.2-2 shows the Security Supervisor reporting to the Emergency Coordinator. Does the Security Supervisor report to the Emergency or Engineering Coordinator?
RESPONSE
The Security Supervisor reports to the Emergency Coordinator. This typographical error will be corrected.
COMMENT 8 Page 6.2-20 says the QA Supervisor is responsible for accounting for all plant personnel and contractor personnel. Is this accountability respon-sibility ongoing or just the initial count? Who has the responsibility for keeping track of persons entering and exiting the plant during the tmergency and recovery?
lES PONSE The Quality Assurance Supervisor is responsible for the initial account-ing for all Plant and contractor personnel. The Emergency Coordinator, assisted by the Radiation Protection Supervisor and the Security Super-visor, is responsible for keeping track of persons entering and exiting the Plant during the emergency using existing access control procedures.
The recovery organization is under development, but it is anticipated that Plant entry and exit will be under normal operation Plant access procedures. Section 5.2 will be revised to clarify this issue.
COMMENT 9a Tables 6.0-1 through -4.
Under notifications the time shown as 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for an " Unusual Event" and 30 minutes for the other three classificatione.
NUREG-0610 says promptly.
Under a " General Emergency" the time should be 15 min.
RESPONSE
See response to McKenna Comment 10.
COMMENT 9b Tables 6.0-1 through -4.
These Tables do not require a writter c10:aout summary as shown in NUREG-0610.
RESPONSE
We disagree with the requirement in NUREG-0610 for a written closeout summary to all offsite Emergency Operations Centers within 24 hr. for an Unusual Event and within 8 hr. for the remaining emergency classifica-tions. The Trojan plant Technical Specifications contain extensive reporting requirements that incude those occurrences which would be classified as an Ususual Event, Emergency Alert, Site tmergency or General Emergency. The State of Oregon Department of Energy receives a copy of all correspondence from PGE to the NRC. We believe that the need for further written followups to other State and county emergency agencies should be decided by mutual agreement between PGE and these agencies.
COMMENT 10 Pages 6.2-2 and 6.2-3.
The Tables referenced in the four paragraphs of Section 6.2.1 are incor-rect. Also Figure 6.4-3, referenced in Paragraph 6.2.1.4 doesn't exist.
RESPONSE
These errors were corrected in the replacement pages forwarded on December 19, 1979.
COMMENT 11 Page 6.2-4, 3rd paragraph of 6.2.2.2.1.1.
Is it the intent that a gross (survey meter or scaler) reading be used to analyze the grab samples?
Will the dose assessment procedure or other procedure show the type of analysis to be used? Normal laboratory ' counting may take considerable time.
RESPONSE
The initial analysis of effluent samples will be done using a portable survey instrument to give a gross activity reading. The procedures for conducting this analysis will be included in Appendix C-2.
COMMENT 12 Page 6.2-12, next to last line, should this figure be 6.2-37
RESPONSE
~
This figure number should be 6.2-3.
The error will be corrected.
COMMENT 13 Page 7.3-1, Section 7.3.1.1.
The second paragraph says the. meteorological data will be communicated to the TSC and ECC by telephone and/or radio. Will there ce readouts in either the TSC or ECC in the future? Also see Item 10 on Page 7.4-4.
RESPONSE
As part of the instrumentation modifications to be implemented by January 1,1981, direct readouts of meteorological instrumentation will be installed at the ECC and the TSC.
COMMENT 14 Page 8.1-6.
The Public Education section does not include a program for determining the effectiveness of the public education. Neither County plan describes a program to check the effectiveness of the public education effort.
RESPONSE
The revised county plans will describe the public education program including periodic surveys to determine the effectiveness of the programs.
COMMENT 15 The licensee's revised plan appears to respond to the various NRC docu-ments and letter covering our site visit in October.
If the various commitments for additional programs, procedures and plan changes made by the licensee, States and Counties are met and the above comments (plus those of the other team members) are resolved in a satisfactory manner, then the TPEP would appear to satisfy the various NRC requirements.
I would be remiss if I failed to comment that the revis.ed TREP probably represents a step backward from being a helpful and workable document during an emergency. As an example, Tables 4.1-1 through 4 describe the four classes of emergency situations, Table 4.2-1 describes the classi-fications for the accidents analyzed in Chapter 15 of the FSAR. There is only one page between these tables and there is a real possibility that a person will mistake Table 4.2-1 for the other tables (4.1-1 through 4).
This will probably result in lost time and confusion. Also more time will be required to determine the class of the incident under the new system than for the old or.a (it's more complicated).
RESPONSE
- 1) Since the specific accidents an41yzed in Chapter 15 of the FSAR are included in the EALs in Tables 4.1-1 through 4.1-4, Table 4.2-1 will be dropped.
- 2) The intent of Tabl'es 4.1-1 through 4.1-4 is not to be used as is to determine EALs during an emergency. The Plant Emergency Instructions and Off-Normal Instructions will be revised to include EALs for each specific accident or situation; therefore, the entire list of EALs for all accidents will not be used by the operations personnel.
SGG/4sa66.51All
- ATTACHMENT 3 COMMENTS BY A. DESROSIERS COMMENT 1 For a General Emergency situation, the EALs on Table 4.1-4 should not include alarms on low-range PRM channels (PRM 1A, 1B or IC), as these PRMs may go offscale before a General Emergency situation exists.
RESPONSE
Table 4.1-4 will be revised to change "PRM-1 high alarm" to "PRM-lD high alarm".
C0KHENT 2 Figure 6.2-1 shows dose ratec inside Containment as a function of Xe-133 equivalent activity and percent of gap or core release. Table 4.1-4 and Section 6.2.2.1.1 refer to ARM-6 readings as being equivalent to the readings in Figure 6.2-1.
ARM-6 is located such that it does not view the entire Containment free volume; if ARM-6 readings are to be used, a correction factor must be included to account for the location of ARM-6.
RESPONSE
High-range Containment radiation monitors will be installed so as to view the entire Containment free volume above Elevation 93 ft. prior to January 1,1981.
ARM-6 readings were used in the RERP only as an interim measure. Table 4.1-4 and Section 6.2 will be modified to correct for the location of ARM-6.
9 SGG/4sa66. *? A18
ATTACHMENT 4 PROPOSED NRC-FEMA ACCEPTANCE CRITERIA IDENTIFIED BY T. McKENNA CRITERION 1 The RERP must specify the qualifications of Plant personnel.
In addition, the new criteria will include staffing requirements for off-hours shif ts.
RESPONSE
This item will be addressed following publication and public comment on the new acceptance criteria.
CRITERION 2 The RERP must specify response times for offsite radiological laboratories.
RESPONSE
Section 7.3 vill be revised to include estimates of response times for offsite radiological laboratories.
CRITERION 3 The RERP must describe followup messages given to offsite agencies after initial notification.
RESPONSE
New Table 6.1-3 will be added to list the information required to be given in follow-up messages to offsite agencies.
CRITERION 4 The new criteria contain exten.ive new requirements for meteorological instrumentation.
RESPONSE
This item'will be addressed following publication and public comment on the new acceptance criteria.
CRITERION 5 The RERP must require evacuation of all nonessent.al Plant personnel for Site Emergencies and General Emergencies.
RES PONSE In practice, this would be done. Section 6.4.1 will be revised to clarify this position.
CRITERION 6 Plant personnel evacuated to the ECC should be accounted for within 30 min., not 45 min. as is required by the current acceptance criteria.
RESPONSE
Section 6.4.1 will be revised to reflect this position.
CRITERION 7 The RERP must describe provisions for 24-hr. capability for performing dose assessments on Plant personnel, and a description of how these records are maintained.
RESPONSE
Section 6.5 will be revised to include the required information.
CRITERION 8 The RERP must include emergency action levels for personnel contamination.
RESPONSE
Section 6.5 will be revised to include the required information.
CRITERION 9 The RERP should describe the recovery organization.
RESPONSE
Section 9.2 states that PGE is currently developing a recovery organi-zation along the lines of the Nuclear Power Plant Emergency Response Plan prepared by the Emergency Response Planning Subcommittee of the AIF Policy Committee on Followup to the Three Mile Island Accident. The details of the recovery organization are expected to be submitted by April 1, 1980.
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9 9
CRITERION 10 Exercises and Drills:
- 1) Every 6 yr. the Plant must hold one exercise during the 6:00-12:00 a.m. time period and one during the 12:00-6:00 a.m. time period.
- 2) The RERP must provide for conducting the following drills (in addition to the annual exercise):
a) Communications drills.
b) Medical emergency drills (annually).
c) Radiation monitoring drills (annually).
d) Health physics drills (semiannually). Health physics drills will include sampling and analysis of effluents in process streams as well as detec-tion of airborne and direct radiation.
- 3) Exercise scenarios shall include the following information:
a) Objective.
b) Date, time and place.
c) Proposed, sequence of events.
d) Time schedule of events.
e) A narrative summary of the scenario.
f) An arrangement to have qualified observers.
- 4) Qualified Federal, State and local representatives shall observe and critique all emergency exercises.
RESPONSE
- 1) Section 8.1.2 of the RERP states that five communications drills will be held annually. One of these exercises will be conducted on the backshift, and one will coincide with the annual exercise.
- 2) Section 8.1.2 will be revised to include the remaining required info rmation.
SGG/4sa66.51A19,